Not surprisingly, in Comment #535221-00071, Jefferey A. Babener, which provides legal services to the DSA, MLMIA, MLM DRA and their member firms is supportive of their efforts to exempt or protect MLM companies from regulation by the FTC. Those of us who donate our time advocating for consumers could not disagree more on their objectives. It would be difficult to find an issue more central to consumer protection than doing everything possible to stop them in their onward march towards complete corruption of the direct selling marketplace. I am in a unique position to comment on Babener’s and other baboonish barristers who have represented such companies as Avon, Shaklee, NuSkin, Nikken, Melaleuca, Excel Communications, ACN, USANA, and Prepaid Legal. Having over 40 years experience in entrepreneurship, legitimate direct selling, sales training, small business consulting, and teaching entrepreneurship as an adjunct instructor, I know the difference between legitimate direct selling and programs that feature an endless chain of recruitment of participants as primary customers. Babener’s recommendations to “Call out the MLM/Direct Selling Exemption and other Typical Exemptions” are in direct opposition to the interests of consumers who need protection by the FTC from product-based pyramid schemes masking as supposedly legitimate “MLM/direct selling companies”. Please read the attached rebuttal of DSA comments in my comment #535221-00091. Respectfully submitted, Jon M. Taylor, MBA, Ph.D., Pres. CONSUMER AWARENESS INSTITUTE, and Pres., Jon Taylor & Co., 291 E. 1850 South, Bountiful, UT 84010. Email: jonmtaylor@juno.com